FEDERAL 

FACILITIES

Selected Facilities’ 

Emergency Plans 

Generally Reflect 

Federal Guidance

Report to the Chairman, Subcommittee 

on Oversight and Management 

Efficiency, Committee on Homeland 

Security, House of Representatives

October 2013

GAO-14-101

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-101, a report to the 

Chairman, Subcommittee on Oversight and 

Management Efficiency, Committee on 

Homeland Security, House of 

Representatives

October 2013

FEDERAL FACILITIES

Selected Facilities’ Emergency Plans Generally 

Reflect Federal Guidance 

Why GAO Did This Study

Recent emergencies, such as

earthquakes in the nation’s capital, 

have raised concerns about how 

prepared federal agencies are in the 

9,600 facilities owned or leased by 

GSA and protected by the Department 

of Homeland Security’s FPS to safely 

evacuate occupants in federal 

buildings. All federal agencies are 

required to prepare OEPs for their 

facilities, which describe actions 

agencies should take to plan for a safe 

evacuation during an emergency. 

GAO was asked to provide information 

on how prepared GSA-owned and 

-leased facilities are to evacuate 

occupants during an emergency. This 

report describes (1) who is responsible 

for ensuring that federal facilities have 

OEPs in place and the extent to which

selected facilities’ OEPs reflect federal 

guidance, and (2) the evacuation 

challenges, if any, selected facilities 

experienced and what actions, if any,

they reported taking to address these 

issues. 

GAO reviewed federal regulations and 

guidance on OEPs, including 

documents from ISC, GSA, and FPS, 

which develop governmentwide 

physical security standards and 

policies, such as minimum elements 

for OEPs. GAO also reviewed OEPs 

and interviewed facility officials at 20 

GSA-owned and -leased facilities, 

selected based on geographic 

dispersion, recent evacuations, and 

facility security level. While not 

generalizable to all GSA-owned and 

-leased facilities the results provided 

perspectives of varying facilities. 

DHS written and technical comments 

were incorporated, as appropriate. 

GSA did not have any comments.

What GAO Found

Federal agencies occupying facilities owned or leased by the General Services 

Administration (GSA) are responsible for preparing and maintaining occupant 

emergency plans (OEP), with assistance or guidance from the Federal Protective 

Service (FPS) and others, and the majority of selected federal facilities’ OEPs

GAO reviewed reflect federal guidance. As required by federal regulations, all 20 

selected facilities had OEPs and had designated officials, who are responsible 

for maintaining OEPs and initiating action according to the OEP in the event of 

an emergency, including the evacuation of facility occupants. Consistent with 

federal guidance, officials at 19 of the 20 selected facilities reported that they 

review and update OEPs at least annually, and officials at 1 facility said they 

were in the process of updating their OEP. When requested, FPS provides OEP 

guidance, such as templates to facility officials. Officials at 14 facilities reported 

using FPS guidance or feedback for their OEPs, officials at 1 facility reported not 

using FPS guidance, and officials at 5 facilities said they used their own agency’s 

guidance. FPS also checks OEPs during periodic facility security assessments—

conducted at least every 3 to 5 years— to assess overall facility risk. GSA 

officials said they have a role in coordinating directly with facilities to provide 

guidance and feedback on OEPs, and to help facility officials plan drills and 

exercises. To assist agency officials as they develop OEPs that best fit individual 

facilities and agency needs, the Interagency Security Committee (ISC), a 

Department of Homeland Security–chaired policy development organization, in 

April 2010 identified 10 minimum elements, such as exercises or evacuating 

occupants with special needs, that should be addressed in an OEP. Thirteen of 

the 20 selected facilities addressed all 10 minimum elements in OEPs or related 

documents. Seven facilities’ OEPs did not address at least 1 of the 10 elements; 

however, lack of an element does not necessarily indicate potential vulnerabilities 

for that facility because the intent of the element may be addressed by other 

procedures or modified based on facility characteristics. For example, evacuation 

exercises were not included in OEPs for 2 facilities located in leased GSA space; 

however, officials said they participate in drills conducted by building 

management. The 20 selected facility OEPs were unique to each facility and how 

OEPs addressed particular elements. 

Officials at 14 of 20 facilities identified evacuation challenges. The most 

frequently cited challenges included employee apathy toward participating in 

drills, accounting for employees, and keeping contact information updated. 

Officials at all but one facility, which was updating its OEP, reported various ways 

they addressed evacuation challenges, including using technology such as entry 

scan systems and radios to track and communicate with employees and making 

evacuation training more interesting to employees. Other incidents and emerging 

threats also prompted officials to change OEPs or evacuation training. For 

example, during the 2011 Washington, D.C., earthquake, officials at selected 

facilities in the D.C. area said that the lack of employee training on earthquake 

procedures may have exposed employees to potential hazards when they selfevacuated. Officials reported revising their OEPs to include procedures for 

earthquakes. Recent shootings also prompted facility officials to revise their 

OEPs and participate in FPS awareness training on active shooter incidents. 

Officials at 6 facilities did not report challenges.

View GAO-14-101. For more information, 

contact Joseph Kirschbaum at (202) 512-9971

or kirschbaumj@gao.gov or Mark Goldstein at 

(202) 512-2834 or goldsteinm@gao.gov . 
Page i GAO-14-101 Federal Facility Evacuations

Letter 1 

Background 4

Individual Agencies Are Responsible for Developing and 

Maintaining OEPs, and the Majority of Selected Facilities’ OEPs 

Generally Reflect Federal Guidance 8

A Majority of Officials in Our Review Reported Responding to 

Challenges Identified during Their Facility Drills and 

Evacuations 16

Agency Comments 20

Appendix I Objectives, Scope, and Methodology 22

Appendix II Examples of How OEP Elements Were Included in 20 Selected 

Facilities’ Emergency Plans 27

Appendix III Comments from the Department of Homeland Security 30

Appendix IV GAO Contacts and Staff Acknowledgments 32

Tables

Table 1: Our Analysis of 20 Selected Occupant Emergency Plan 

(OEP) Features and Selected Facility Characteristics 15

Table 2: Selected Facility Characteristics of the 20 Case Study 

Facilities in Our Review 24

Table 3: How Selected Facility Occupant Emergency Plans (OEP) 

Addressed Interagency Security Committee OEP Elements 27

Figures

Figure 1: Facility Security Level Factors and Facility Security Level 7

Figure 2: Evacuation Challenges Identified by 20 Selected Federal 

Facilities 17

Contents 
Page ii GAO-14-101 Federal Facility Evacuations

Abbreviations

DHS Department of Homeland Security

EEOC U.S. Equal Employment Opportunity Commission

FPS Federal Protective Service

FSL facility security level

GSA General Services Administration

ISC Interagency Security Committee

MIST Modified Infrastructure Survey Tool

OEP occupant emergency plan

REXUS Real Estate Across the United States

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Page 1 GAO-14-101 Federal Facility Evacuations

441 G St. N.W.

Washington, DC 20548

October 25, 2013

The Honorable Jeff Duncan 

Chairman, Subcommittee on Oversight 

 and Management Efficiency 

Committee on Homeland Security 

House of Representatives

Dear Mr. Chairman:

Recent natural disasters, such as earthquakes in the nation’s capital, and 

fatal attacks, such as the shooting at the Long Beach, California, federal 

building in February 2012, have raised concerns about emergency 

preparedness in approximately 9,600 facilities owned or leased by the 

General Services Administration (GSA) and protected by the Department 

of Homeland Security’s (DHS) Federal Protective Service (FPS).1 All 

federal agencies are required to prepare occupant emergency plans 

(OEP) for their facilities, which describe the actions that officials should 

take to plan for safe evacuations during an emergency.2

 

1

The Washington, D.C., area experienced a magnitude 3.6 earthquake on July 16, 2010, 

and a magnitude 5.8 earthquake on August 23, 2011. On February 16, 2012, agents at 

the U.S. Immigration and Customs Enforcement office in Long Beach were involved in a 

workplace violence incident; one was wounded and one killed.

The Interagency 

Security Committee (ISC)—a DHS-chaired interagency organization that 

develops government-wide physical security standards and is responsible 

for enhancing the protection of federal facilities—as well as GSA and FPS 

provide guidance to officials in GSA-owned and -leased facilities to assist 

in developing OEPs. Given the importance of safely evacuating federal 

employees and visitors from federal facilities in an emergency, you asked 

us to provide information on how prepared federal facilities owned and 

leased by GSA are to evacuate occupants during an emergency. This 

report describes (1) who is responsible for ensuring that GSA-owned and 

-leased facilities have OEPs in place and the extent to which selected 

facilities’ OEPs reflect federal guidance, and (2) the evacuation 

challenges, if any, that selected facilities experienced and what actions, if 

any, they reported taking to address these issues.

2

See 41 C.F.R. §§ 102-74.230 to .260. 

 
 

Page 2 GAO-14-101 Federal Facility Evacuations

To describe who is responsible for ensuring that OEPs are in place, we 

reviewed federal laws, regulations, executive orders, and guidance 

related to the oversight of federal facilities, and guidance issued for 

agencies by ISC, GSA, and FPS.3 We also reviewed our previous work 

on the roles of ISC, GSA, and FPS in protecting federal properties.4

To determine the extent to which selected facilities’ OEPs reflected 

federal guidance, we conducted site visits at 20 GSA-owned and -leased 

facilities in Washington, D.C.; Los Angeles, California; and Kansas City, 

Missouri.

We 

interviewed relevant senior officials from those three agencies regarding 

their agencies’ role in ensuring that federal facilities have OEPs in place.

5 We selected a nonprobability sample of facilities based on 

factors such as geographical dispersion and reporting of an evacuation 

incident in 2011 or 2012, as well as to reflect a mix of GSA-owned and 

-leased properties and facility security levels (FSL).6

 

3

Among others, guidance we reviewed included the following: ISC, Physical Security 

Criteria for Federal Facilities: An Interagency Security Committee Standard, (Washington, 

D.C.: April 12, 2010) and Occupant Emergency Programs: An Interagency Security 

Committee Guide (Washington, D.C.; March 2013); FPS, Secure Facilities, Safe 

Occupants–Occupant Emergency Plans: Development, Implementation and Maintenance, 

Updated May 2010, and related supplements; and GSA’s Public Buildings Service, 

Occupant Emergency Program Guide, (Washington, D.C.: March 2002). 

Appendix I contains 

a table of the characteristics of our 20 selected facilities. For each facility, 

we obtained the facility OEP and compared it with the 10 minimum 

elements that should be in an OEP, such as the circumstances for 

activating the OEP, based on ISC’s Physical Security Criteria for Federal 

4

GAO, Federal Real Property Security: Interagency Security Committee Should 

Implement a Lessons-Learned Process, GAO-12-901 (Washington, D.C.: Sept. 10, 2012); 

Federal Protective Service: Actions Needed to Resolve Delays and Inadequate Oversight 

Issues with FPS’s Risk Assessment and Management Program, GAO-11-705R 

(Washington, D.C.: July15, 2011); and Homeland Security: Greater Attention to Key 

Practices Would Improve the Federal Protective Service’s Approach to Facility Protection, 

GAO-10-142 (Washington, D.C.: Oct. 23, 2009).

5

GSA reported having over 9,600 assets, or 11 percent of all federal assets, in September 

2012, which includes office buildings, courthouses, warehouses, laboratories, parking lots,

and other properties. We selected facilities from the almost 7, 900 GSA office buildings, of 

which 7,301 are office spaces that GSA leases. For the purposes of this report, we use 

the term “facilities” to describe the 20 GSA assets in our sample. We selected these three 

cities to reflect geographically-diverse areas and a range of concentrations of GSA 

facilities.

6

FPS assigns an FSL of I to V to facilities it protects. A higher-numbered FSL facility 

would be considered a higher security risk than a lower-numbered FSL facility.
 

Page 3 GAO-14-101 Federal Facility Evacuations

Facilities: An Interagency Security Committee Standard, April 12, 2010 

(ISC 2010 standard).7

To describe evacuation challenges and actions taken to address them, 

we interviewed officials with OEP responsibilities at the 20 selected 

facilities. We relied on officials’ statements regarding what was 

considered a challenge and how such issues were resolved. Where 

available, we reviewed after-action reports documenting facility 

evacuation experiences. We discussed evacuation experiences and 

challenges with ISC, FPS, and GSA officials in Washington, D.C., and 

with FPS officials who are located in the three site visit areas. Our 

findings regarding what issues presented challenges and how such 

challenges could be resolved cannot be generalized to all GSA-owned 

and -leased facilities; however, they provided specific examples of issues 

We used the ISC 2010 standard’s suggested 

elements because ISC’s 2013 guidance was not finalized when we 

conducted our work or available when the plans we reviewed were 

developed. ISC officials said the elements identified in the ISC 2010 

standard are incorporated in the 2013 ISC guidance. The elements in the 

2010 ISC standard are general in nature, as the same element may be 

addressed in various ways based on agency preferences and differences 

in facility characteristics, and all of the elements are not always applicable 

to every facility (e.g., if the facility did not have a child care facility). 

Because of the general nature of the elements, we assessed whether an 

element was present in a facility’s OEP, not how comprehensively or

thoroughly it was addressed. At each of the 20 facilities, we interviewed 

GSA property managers and officials from agencies who occupy the 

facility. In instances where a particular element was not identified in an 

OEP, we discussed with officials how that element related to the 

characteristics of the facility. While the findings from our 20 case studies 

are not generalizable to all GSA-owned and -leased facilities, they 

provide specific examples of how selected facilities have addressed 

emergency plan requirements and provide insights from a range of 

federal facilities.

 

7

ISC, Physical Security Criteria for Federal Facilities: An Interagency Security Committee 

Standard. While federal facility officials are required to follow the ISC Physical Security 

Criteria, the elements listed in the criteria are suggested because the language indicates 

that the elements “should be” included, recognizing that adjustments may be made as 

appropriate for the facility. ISC’s 2013 Occupant Emergency Programs Guide expands on 

information that should be in an OEP. 
 

Page 4 GAO-14-101 Federal Facility Evacuations

encountered and how varying facilities addressed them. Further details of 

our scope and methodology are contained in appendix I.

We conducted this performance audit from August 2012 to October 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Federal agencies are required to have an occupant emergency program 

that establishes procedures for safeguarding lives and property during 

emergencies in their respective facilities.8

Several federal entities—ISC, GSA, and FPS—play a role in protection 

policy and programs for GSA-owned and -leased facilities.

According to ISC, an OEP is a 

critical component of an effective occupant emergency program. Further, 

these plans are intended to minimize the risk to personnel, property, and 

other assets within a facility by providing facility-specific response 

procedures for occupants to follow.

Established by Executive Order 12977, ISC is an interagency 

organization chaired by DHS to enhance the quality and effectiveness of 

security in, and protection of, nonmilitary buildings occupied by federal 

employees for nonmilitary activities in the United States, among other 

things.9

 

8

See 41 C.F.R. §§ 102-74.230 to .260.

 ISC includes members from 53 federal departments and 

agencies, including FPS and GSA. Under the executive order, ISC was 

directed to develop policies and standards that govern federal facilities’ 

physical security efforts. As a part of its government-wide effort to 

develop physical security standards and improve the protection of federal 

facilities, it also provides guidance on OEPs. In its 2010 standard, ISC 

9

Exec. Order No. 12,977, 60 Fed. Reg. 54,411 (Oct. 19, 1995).

Background 

ISC 
 

Page 5 GAO-14-101 Federal Facility Evacuations

lists 10 elements that should be addressed at a minimum in an OEP, and 

states that the plan must be reviewed annually.10

As the federal government’s landlord, GSA designs, builds, manages, 

and maintains federal facilities. Presidential Policy Directive 21 

designates DHS and GSA as cosector-specific agencies for the 

government facilities sector, 1 of 16 critical infrastructure sectors.11 In 

2002, GSA issued its Occupant Emergency Program Guide to provide 

step-by-step instructions for agencies to use to meet federal regulatory 

requirements for OEPs.12 GSA also served as chair and sponsor of ISC’s 

working group that developed additional guidance for preparing OEPs.13

The Homeland Security Act of 2002 transferred FPS from GSA to the 

newly established DHS in March 2003, and required DHS to protect the 

buildings, grounds, and property that are under the control and custody of 

GSA and the persons on the property.14 As part of an agreement between 

GSA and DHS, FPS provides law enforcement and related security 

services for GSA’s approximately 9,600 facilities, which include—but are 

not limited to—responding to incidents and conducting facility security 

assessments.15

 

10ISC, Physical Security Criteria for Federal Facilities: An Interagency Security Committee 

Standard. According to ISC, its 2013 guidance on occupant emergency programs 

incorporates all 10 minimum OEP elements.

Facility security assessments are conducted by FPS 

inspectors to help FPS identify and evaluate potential risks so that 

countermeasures can be recommended to help prevent or mitigate risks. 

FPS inspectors are law enforcement officers and trained security experts 

who perform facility security assessments and inspections and respond to 

11The White House, Presidential Policy Directive 21, Critical Infrastructure Security and 

Resilience (Washington, D.C.: Feb. 12, 2013). This directive establishes national policy for 

critical infrastructure and, among other things, assigns roles and responsibilities to specific 

federal agencies for different critical infrastructure sectors. 

12See 41 C.F.R. §§ 102-74.230 to .260.

13ISC, Occupant Emergency Programs: An Interagency Security Committee Guide. 

146 U.S.C. § 203(3); 40 U.S.C. § 1315. 

15Memorandum of Agreement between the Department of Homeland Security and the 

General Services Administration, June 8, 2006.

GSA

FPS
 

Page 6 GAO-14-101 Federal Facility Evacuations

incidents. FPS also assigns an FSL in accordance with the ISC standard 

and in coordination with the FSC and GSA representative based on a 

facility’s cumulative rating on five factors established by ISC (plus an 

adjustment for intangible factors), as shown in figure 1. According to ISC, 

a facility’s FSL is a key factor in establishing appropriate physical security 

measures. Further, while the minimum OEP elements in the ISC 2010 

standard apply to all FSL facilities, what is appropriate may vary based on 

facility characteristics.
 

Page 7 GAO-14-101 Federal Facility Evacuations

Figure 1: Facility Security Level Factors and Facility Security Level
 

Page 8 GAO-14-101 Federal Facility Evacuations

The federal agencies that occupy federal facilities are responsible for 

preparing and maintaining OEPs; ISC, GSA, and FPS provide guidance 

or assistance to the agencies in developing OEPs, and FPS can 

periodically review OEPs. All 20 facilities we visited had written 

emergency plans in place, the majority of which reflected ISC’s minimum 

elements for a facility OEP. The OEPs we reviewed varied in length and 

content based on a number of factors, such as facility security level.

Ensuring that each of the approximately 9,600 GSA-owned and -leased 

facilities protected by FPS has emergency plans to safely evacuate 

occupants is a complex undertaking. Each agency occupying a facility is 

responsible for ensuring the safety of its occupants in that facility. 

Although no one agency accounts for OEPs across the federal 

government, ISC, GSA, and FPS each provide guidance on what should 

be included in a plan. FPS also provides a check that plans are in place 

as part of its periodic facility security assessments.

Federal agencies have designated officials to create and oversee 

emergency plans and duties for the facilities they occupy. According to 

federal regulations, designated officials are responsible for developing, 

implementing, and maintaining the OEP for the facility.16

ISC is responsible for issuing policies and standards on facility protection, 

such as OEPs, but does not review the extent to which federal facilities 

have OEPs. As previously mentioned, ISC listed 10 minimum elements in 

In the event of 

an emergency, the designated official is expected to initiate appropriate 

action according to the OEP, including the evacuation and relocation of 

facility occupants. The designated official is also to establish, staff, and 

train an Occupant Emergency Organization, which is to be composed of 

employees from within agencies designated to perform the requirements 

established by the plan. We found that all 20 facilities we visited had 

assigned designated officials to perform these duties.

 

1641 C.F.R. § 102-74.230.

Individual Agencies 

Are Responsible for 

Developing and 

Maintaining OEPs, 

and the Majority of 

Selected Facilities’ 

OEPs Generally 

Reflect Federal 

Guidance 

Agencies Are Responsible 

for OEPs with Assistance 

from ISC, GSA, and FPS

Federal Agencies’ 

Responsibilities

ISC Involvement
 

Page 9 GAO-14-101 Federal Facility Evacuations

its ISC 2010 standard that an OEP should address.17 In March 2013, ISC 

issued Occupant Emergency Programs: An Interagency Security 

Committee Guide, to further assist department and agency officials as 

they develop and review their occupant emergency programs, including 

how to develop OEPs that best fit their individual facility and agency 

needs.18

GSA also plays a role in coordinating directly with facilities to provide 

guidance on OEPs and participates in emergency planning efforts. 

According to GSA officials, its tenant agencies, through their designated 

officials, are responsible for tracking and reviewing OEPs. Further, 

designated officials are to represent the government’s interests to public 

safety and emergency response in conjunction with GSA and other key 

stakeholders. However, GSA officials said that they will assist agencies 

with OEPs as requested. GSA officials also told us that they participate 

on facility security committees and in planning drills and exercises, and 

can provide GSA and other OEP guidance to their tenants. GSA officials 

also said that they work with tenants, as well as building owners at leased 

facilities, to ensure that facilities comply with building safety codes, such 

as having appropriate exits and fire alarms.

According to ISC officials, the guidance was disseminated via email to the full ISC membership, which includes 53 federal agencies and 

departments. ISC officials said they rely on agencies located in federal 

facilities to ensure OEPs are in place and shared several reasons why it 

would not be feasible for ISC to comprehensively review OEPs. First, 

according to these officials, ISC decided to use broad guidelines that 

would allow agencies to develop plans that are suited to the unique 

characteristics of their facilities. As a result, the guidance does not 

provide specific standards or metrics against which to compare a facility’s 

plan. Second, although OEPs are an important part of an overall 

occupant emergency program, ISC officials said that OEPs are a 

relatively small part of an agency’s overall emergency and security 

planning, which may not warrant implementing additional monitoring and 

data-gathering efforts. Last, ISC officials cited staffing constraints and 

noted that, per Executive Order 12977, they rely on volunteers from 

member organizations to carry out the committee’s efforts.

19

 

17ISC, Physical Security Criteria for Federal Facilities: An Interagency Security Committee 

Standard. 

Presidential Policy Directive 

18ISC, Occupant Emergency Programs: An Interagency Security Committee Guide. 

19See 41 C.F.R § 102-74.360.

GSA Involvement 
 

Page 10 GAO-14-101 Federal Facility Evacuations

21 jointly assigns FPS and GSA responsibility for critical infrastructure 

protection of the government facilities sector.20

FPS is responsible for assisting federal agencies with guidance, training, 

exercises, and drills, and also conducts periodic facility security 

assessments that include checking OEPs. FPS officials in the three cities 

we visited said that, when requested, they provide agencies with OEP 

guidance, which includes an OEP template, and advise the designated 

and other agency officials regarding an emergency plan that is 

appropriate for their location and circumstances. According to FPS 

officials, its OEP template (a Microsoft Word file) can be requested from 

the DHS and GSA websites and can also be made available to agency 

officials on a DVD. Of the 20 facilities we visited, officials at 14 reported 

using FPS guidance or feedback on their OEPs, for example, using the 

FPS template as a base for their OEPs and officials at 5 facilities reported 

using their own agency guidance for OEP development. FPS officials in 

one city we visited reiterated that some agencies have their own 

emergency coordinators and choose not to use FPS materials. Officials at 

1 facility reported not using FPS or other agency guidance for OEP 

development.

According to a GSA 

Associate Administrator, there is a need for greater visibility of OEPs. 

Consequently, GSA and FPS officials told us they have initiated 

discussions on future collaboration to ensure OEPs are in place and 

updated at GSA facilities. According to GSA officials, as part of a Joint 

Strategy for Facility Resilience, GSA and FPS will work collaboratively to 

develop a platform that could serve as a repository for OEPs, facility 

security assessments, and other data over the next 2 to 4 years.

FPS also provides evacuation training, including awareness training on 

active shooter and workplace violence incidents,21 as well as safety and 

security.22

 

20The White House, PPD 21: Critical Infrastructure Security and Resilience.

Officials from 5 of the 20 facilities we visited mentioned specific 

training FPS had provided them, primarily active shooter awareness 

21An active shooter is an individual actively engaged in killing or attempting to kill people 

in a confined and populated area.

22According to the memorandum of agreement between DHS and GSA, DHS will provide 

training as requested on the basic concepts and procedures of an OEP and update the 

OEP guidance as necessary. FPS does not track delivery of all training provided at 

facilities for all regions.

FPS Involvement 
 

Page 11 GAO-14-101 Federal Facility Evacuations

training, and officials at 1 facility stated that they were planning an active 

shooter exercise with FPS.

Additionally, FPS inspectors in the three locations we visited said they 

make themselves available to participate in facility exercises and 

emergency drills, and officials at 11 of the 20 facilities we visited told us 

that FPS had participated, for example, by providing traffic control 

services or ensuring all occupants have evacuated. Officials at 5 facilities 

we visited mentioned that FPS had not consistently participated in drills at 

their facilities, in one case because FPS had not been invited and in 

another case because FPS arrived after the drill had been completed.23

FPS inspectors also are to check and answer a series of questions about 

the facility’s OEP during periodic facility security assessments, including 

whether or not the facility has a written OEP, and consider whether it 

addresses the 10 minimum elements for an OEP identified by ISC. FPS’s 

facility security assessments are to occur periodically, every 3 to 5 years, 

depending on the security level of the facility.

According to FPS officials, FPS participation in exercises and drills can be 

limited if FPS personnel are not nearby, are on duty responding to actual 

incidents, or were not given advance notice.

24 In July 2011, we reported 

that FPS could not complete security assessments as intended because 

of limitations in its assessment tool, among other reasons.25 We 

recommended that the agency evaluate whether other alternatives for 

completing security assessments would be more appropriate. DHS 

agreed with the recommendation and has developed a new facility 

security assessment tool, the Modified Infrastructure Survey Tool (MIST), 

which DHS officials said was deployed in April 2012. FPS headquarters 

officials told us that its agency currently has no national data on which 

agencies have an OEP, and we previously reported that MIST was not 

designed to compare risk across federal facilities.26

 

23Officials in the remaining 4 facilities did not provide information on whether FPS 

participated in drills or exercises.

FPS headquarters 

officials said as the agency moves forward with enhancing MIST’s 

24Facility security assessments are to be conducted at least every 5 years for level I and II 

facilities and at least every 3 years for level III and IV facilities.

25GAO-11-705R. 

26GAO, Federal Protective Service: Actions Needed to Assess Risk and Better Manage 

Contract Guards at Federal Facilities, GAO-12-739 (Washington, D.C.: Aug. 10, 2012). 
 

Page 12 GAO-14-101 Federal Facility Evacuations

capabilities, it would consider whether it was feasible to add a feature that 

would allow it to aggregate data across facilities, such as the status of 

OEPs.

According to FPS officials, recommendations about OEPs and evacuation 

processes, such as suggestions to change assembly points in the event 

of an evacuation, may be made during facility security assessments. For 

example, one FPS inspector recommended that 1 facility change its 

assembly point because he determined that it was too close to the 

evacuated facility. Although officials at this facility expressed some 

reluctance in changing the assembly location, the inspector told us that 

facilities generally implement FPS suggestions. FPS inspectors also said 

that there have been few examples where agencies did not want to 

comply. Although agencies do not have to comply with their 

recommendations on OEPs, FPS inspectors stated that they do have 

enforcement authority related to life safety issues during an actual 

emergency event, such as moving occupants to different evacuation 

locations. Further, FPS headquarters officials said recommendations 

about OEPs may be made at any time, not just during facility security 

assessments. 

All 20 facilities we visited had written OEPs, as required by regulation, 

which included evacuation procedures. Consistent with the ISC 2010 

standard that plans should be reviewed annually, officials at 19 of the 20 

facilities we visited reported that they review, and update as needed, their 

emergency plans on at least an annual basis, and some reported 

reviewing their plans more frequently. For example, officials at 1 FSL-II 

facility reported that the OEP program manager reviews the plan on a 

monthly basis, and officials at a FSL-IV facility said their plan was 

reviewed quarterly. The OEPs we examined had been reviewed by 

officials in the past year, except for one. Officials at this FSL-III facility 

reported that they have an emergency plan in place; however, their OEP 

had not been annually reviewed, and was last updated in 2004. Officials 

at that facility said that a revision was currently under way. Officials at all 

20 facilities told us they conduct at least one annual evacuation drill, as 

directed in the ISC 2010 standard, with several officials reporting their 

facility conducts multiple drills each year.

We analyzed the extent to which the selected facilities’ OEPs 

incorporated elements that should be in an OEP according to the ISC 

2010 standard, which outlines 10 minimum elements:

The Majority of Selected 

Facilities’ OEPs Generally 

Reflect Federal Guidance
 

Page 13 GAO-14-101 Federal Facility Evacuations

1. purpose and circumstances for activation,

2. command officials and supporting personnel contact information,

3. occupant life safety options (e.g., evacuation, shelter-in-place),

4. local law enforcement and first responder response,

5. special needs individuals (e.g., those with disabilities, or who are 

deaf),

6. visitors,

7. special facilities (e.g., child care centers),

8. assembly and accountability,

9. security during and after incident, and

10. training and exercises.

We found that 13 of the 20 facilities addressed all of the minimum 

elements that were applicable; in some of these cases, OEP elements 

were addressed in other emergency documents, such as supplemental 

child care OEPs.27 Seven of the facilities did not address at least one 

OEP element in the ISC 2010 standard in their OEPs or other documents. 

That an element was not in the plan or in related documents for 7 facilities 

does not necessarily indicate potential vulnerabilities for these facilities 

because other procedures or facility services may address the intent of 

the OEP element. For example, 6 of the 7 OEPs did not specifically 

describe security during or after an emergency event.28

 

27Not all elements were applicable for all facilities, for example, some facilities did not 

have an associated special facility. For applicable elements in other documents, we 

verified that the element was in other emergency documents. ISC’s 2010 standard on 

OEP minimum elements does not explicitly require that OEP elements be addressed in a 

single document. 

Officials in all six 

cases identified existing security, such as building security guards, as 

having responsibility. Officials at 2 facilities reported that they were 

updating their OEPs after our site visit and would identify existing security 

in the plans. As another example, at 2 facilities where training or 

exercises were not included in the OEPs, officials at both facilities (which 

were housed in leased GSA space) said that building management 

conducts drills and that they participate. The 2010 standard and 2013 ISC 

28The ISC guidance does not provide a further description of what this or the other 9 

elements should contain. In our review we looked for any general reference to security 

during or after an emergency event.
 

Page 14 GAO-14-101 Federal Facility Evacuations

guidance both allow for necessary adjustments to be made to a facility’s 

emergency plan based on specific requirements or needs.

Plans at the 20 facilities we reviewed were unique to each facility, and 

there were differences in how each element was addressed, as the ISC 

2010 standard and 2013 guidance allow. Specific details on how OEP 

elements are expected to be addressed are not included in ISC’s 2010 

standard, which we used to review facility OEPs, or in ISC’s 2013 

guidance. ISC officials said that there is so much variability among 

facilities that it is difficult to identify what would be appropriate for all 

facilities.29

We did observe some commonality in the 20 facility OEPs we reviewed, 

based on facility characteristics such as security level, whether the facility 

was GSA owned or leased, and occupant characteristics, as shown in 

table 1.

For example, in one plan, command official information might 

include multiple contacts and a detailed list of responsibilities for each 

official, while another plan refers occupants to security services, which 

would be responsible for contacting command officials. Appendix II 

provides other examples of variation in how facilities addressed the 10 

minimum elements in the plans we reviewed.

 

29Consistent with ISC’s approach, FPS (in its protocol for review of OEPs during a facility 

security assessment) notes that the scope and complexity of the OEP are dependent on 

the facility’s size, population, and mission.

Selected OEPs Varied 

Based on a Number of 

Factors, Consistent with 

the ISC Standard
 

Page 15 GAO-14-101 Federal Facility Evacuations

Table 1: Our Analysis of 20 Selected Occupant Emergency Plan (OEP) Features and Selected Facility Characteristics 

Facility characteristics OEP features

Facility security level The 9 FSL-IV facilities we reviewed were larger facilities and had more detailed emergency plans 

than the 6 FSL-II, smaller facilities. For example, 1 FSL-IV facility developed a 56-page OEP, a child 

care center OEP supplement, and an OEP flip chart that each employee is to receive, whereas 1 

FSL-II facility had an abbreviated six-page OEP.a

For the 20 OEPs we reviewed, larger facilities with more occupants tended to have a more detailed 

structure for assembly and accountability during an evacuation than did smaller facilities, for example, 

establishing specific positions such an assembly area monitor to communicate with the command 

center. At smaller facilities, facility plans identified the heads of operating units, managers, and 

supervisors as responsible for staff accountability in an emergency situation.

Facility is owned or leased ISC’s 2010 standard and 2013 guidance apply to both owned and leased GSA facilities. All 6 of the 

FSL-II facilities, 4 of the 5 FSL-III facilities, and 1 of the 9 FSL-IV facilities that we met with—in total 

11 of the 20—were in leased space. (Ninety-three percent of all GSA office facilities are in leased 

space.) Officials at 2 facilities that were tenants in leased commercial space reported that they rely in 

part on emergency plans developed by the building management for evacuation purposes. For 

example, 1 facility had an emergency plan that described evacuation procedures, but officials 

explained that the circumstances that would call for an evacuation were outlined in the lessor’s 

building emergency plan.

In 7of the 9 GSA-owned facilities we visited, officials reported having facility security committees that 

are to play a role in the development and maintenance of the facility OEP, whereas none of the 

officials in the 11 leased facilities reported having a facility security committee.

Occupant characteristics Occupant characteristics were also a factor in OEP content in the 20 OEPs we analyzed. Facilities 

with visitors had plans that addressed visitor evacuation needs, whereas those with few or no visitors

did not emphasize this element in their plans. For example, officials at 1 FSL-IV facility said visitors 

are rare, while officials at another FSL-IV facility said they have over 1,000 visitors to the facility each 

day, and contract guards help ensure their safety. At least 2 facilities supplemented their OEPs by 

providing brochures containing evacuation information to visitors.

Facility plans we analyzed also reflected provisions for persons with disabilities. Officials at 1 of the 3 

facilities where the OEP did not include provisions for persons with special needs reported that they 

did not have special need occupants at the facility.

Source: GAO analysis of facility OEPs.

a

GSA allows the use of an abbreviated OEP for its’ small ,storefront facilities.
 

Page 16 GAO-14-101 Federal Facility Evacuations

Officials at 14 of 20 facilities in our review identified challenges, and all 

but one reported responding to challenges they encountered in 

developing and implementing emergency evacuation procedures.30

As shown in figure 2, officials at facilities we visited identified several 

challenges they addressed. The top three challenges cited by officials at 

the14 selected facilities that identified challenges were (1) participation 

apathy (10 facilities),

Officials at 6 facilities said that they did not identify any challenges. Half of 

the officials reporting challenges told us that actual emergency events 

and exercises helped to identify issues and mitigation steps that allowed 

their facilities to generally carry out effective emergency evacuations. For 

example, the majority of officials at facilities we visited in Washington, 

D.C., who experienced the 2011 earthquake said that because of the lack 

of earthquake procedures or training, emergency teams could not control 

employees’ evacuation process. They said that many employees 

essentially self-evacuated, exposing themselves to hazards such as 

falling debris and, in one case, evacuated to an unsafe assembly area 

under an overpass. These officials said that they have since researched 

proper earthquake procedures, and have revised or are in the process of 

revising their OEPs accordingly.

31 (2) knowing which employees are present (9 

facilities), and (3) keeping plan information current (7 facilities). The 

remaining challenges were cited by 6 or fewer of the selected facilities.32

 

30Officials at facilities we visited determined whether they perceived an issue to be a 

challenge or not. We asked officials at all 20 facilities if they experienced specific 

challenges. In addition, officials in all but 1 of the 14 facilities with challenges provided 

additional information on actions taken to mitigate the challenges, which we include as 

examples. 

31For purposes of this report, we used “participation apathy” to refer to what various 

officials described as employees unwillingness or lack of interest in participating in 

emergency drills or as members of an emergency team. 

32Officials at 11 facilities reported addressing more than one challenge.

A Majority of Officials 

in Our Review 

Reported Responding 

to Challenges 

Identified during 

Their Facility Drills 

and Evacuations
 

Page 17 GAO-14-101 Federal Facility Evacuations

Figure 2: Evacuation Challenges Identified by 20 Selected Federal Facilities

Officials at all but 1 facility provided additional detail regarding actions 

they are taking to mitigate facility evacuation challenges. Officials at that 

facility reported that the OEP was to be updated, but did not describe how 

they specifically plan to mitigate OEP challenges they identified.33

For each of the top three challenges, officials at facilities that cited 

challenges described some of the actions taken to address those 

challenges.

• Employee participation apathy. Officials at 10 of the 20 selected 

facilities cited apathy as a challenge they encountered, such as 

employees not participating in or responding quickly to drills; not 

wanting to stop working or leave the building; not reporting to the 

assembly area (e.g., going for a coffee break during an evacuation 

 

33Officials at this facility identified four challenges, which are the same top four challenges 

that were identified by the 20 facilities overall, as shown in figure 2. 
 

Page 18 GAO-14-101 Federal Facility Evacuations

drill); and not volunteering for emergency team responsibilities, such 

as becoming a floor warden. Officials at 9 of the 10 facilities described 

a variety of actions to address this challenge, Officials at 5 facilities 

said that leadership plays a role, such as leading by example, or 

drawing management or supervisory attention to nonparticipants. For 

example, at 1 facility, officials said supervisors were notified of the 

lack of participation in emergency drills and training and asked to 

emphasize the importance of participation. Officials at another facility 

indicated that senior leaders lead by example, responding quickly and 

taking emergency drills and participation seriously to encourage 

employees to take emergency responsibilities seriously. Officials at 3 

facilities said they address apathy by using drills, an awareness 

campaign, or other efforts to promote participation. At the other 2 

facilities where this challenge was identified, officials at 1 facility said 

they were reviewing challenges and action options, and the other did 

not provide information on any mitigating activities. Officials at the 

third facility said that they made efforts to make emergency and 

evacuation training more interesting and interactive to maintain 

employee interest and attention, such as implementing a game meant 

to teach about various emergency situations and proper procedures.

• Knowing which employees are present (accounting for 

employees). Officials at 9 of the 20 selected facilities reported 

encountering this challenge, with employees teleworking or working 

offsite as a contributing factor. Officials at 8 facilities provided various 

examples of addressing this challenge. At 6 facilities, officials said 

they relied on supervisors, managers, and sign-in sheets to keep track 

of employees. Officials at 2 facilities mentioned using or planning to 

use technology to account for employees in an emergency situation. 

One facility is developing an emergency notification system that sends 

emergency information to as many as 10 different electronic devices 

to contact an individual and determine the individual’s location. 

Another facility is planning to use an entry scan system that records 

who is in the building and can provide a list to take roll at the 

evacuation rally point to account for employees. At 1 facility, where 

officials reported they are updating their OEP, efforts to mitigate this 

challenge were not described.

• Keeping emergency contact information updated. Officials at 7 of 

the 20 facilities said that it was an ongoing challenge to keep 

emergency contacts in the OEP current because of changes in an 

employee’s contact information or status such as a transfer or 

retirement. To address this challenge, officials at 6 facilities said they 

review and update contact information at various points, such as 
 

Page 19 GAO-14-101 Federal Facility Evacuations

when staff leave; before drills; or on a daily, weekly, monthly, or 

quarterly basis at different facilities. At one facility, officials said that 

they rely on tenants to provide notice of personnel changes. At 

another, an official said that the facility’s technology department was 

able to align its employee finder database with the agency’s 

separation database to automatically flag when employees have a 

change in location or status. Information was not available for 1 facility 

on any efforts to mitigate this challenge.

Officials at facilities we visited reported experiencing and addressing 

other challenges less frequently such as keeping employees trained, 

evacuating the public and persons with physical handicaps, 

communicating about an evacuation, and coordinating with other building 

tenants. Officials who reported encountering these challenges told us that 

they had mechanisms in place to mitigate the challenges they 

encountered, such as the use of hand-held radios for communications, so 

the challenges were not considered an issue that prevented them from 

carrying out effective emergency evacuations.

Other incidents or situations have also prompted facilities to revise their 

OEPs or for FPS to evaluate emerging threats and revise its training, as 

discussed in the examples below.

• Practice drills. During a practice drill evacuation at 1 facility, it was 

discovered that the path to the evacuation assembly area was up a 

steep slope and that some of the employees could not make the 

climb. The assembly area was subsequently changed and the OEP 

revised.

• Emerging threats. FPS headquarters officials stated that recent 

media coverage of active shooter situations has increased the public’s 

perception of this threat to facility safety and security. A fatal active 

shooter incident at 1 facility in Los Angeles prompted the revision of 

safety and evacuation procedures. FPS headquarters officials said 

that FPS has developed awareness training courses for how to handle 

an active shooter situation, and has proactively offered this training to 

facilities.

To identify and help agencies address evacuation or OEP challenges, 

officials at ISC, GSA, and FPS said that they provide initial guidance 

regarding the OEP, and may provide additional assistance if requested by 

facilities or agencies. For example, ISC officials stated that they issued 

their March 2013 OEP Program Guidance in response to concerns raised 

by ISC’s members for consistency in OEP guidance. Officials said 
 

Page 20 GAO-14-101 Federal Facility Evacuations

agencies experiencing a challenge regarding their OEPs (or other issues) 

can ask ISC for specific help such as one-on-one assistance, or referral 

to other agency officials that have addressed a similar challenge. Also, 

ISC officials said a working group can be created to identify solutions to 

an issue, as was the case in developing the 2013 guidance. As discussed 

earlier, GSA and FPS have published OEP information, and may provide 

additional information or training assistance in meeting specific 

challenges on a case-by-case basis.

We provided a draft of this report to DHS and GSA for review and 

comment.34

In its written comments, DHS reiterated that OEPs are critical in safely 

evacuating federal facility occupants in an emergency. DHS noted that 

GAO recognized the complex roles performed by the ISC, GSA, FPS, and 

agency officials to ensure that the approximately 9,600 GSA-owned and 

-leased facilities have an OEP. For instance, DHS cited that ISC 

establishes standards and guidance for developing OEPs that are 

responsive to individual facility needs, whereas FPS is responsible for 

coordinating with and assisting department and agency officials in 

developing facility OEPs, and providing agencies with evacuation training, 

among other things. DHS also stated that it is committed to working 

collaboratively with ISC and GSA to identify and mitigate security-related 

vulnerabilities at federal facilities.

GSA had no comments on the report. DHS provided technical 

comments, which were incorporated as appropriate. DHS also provided 

written comments, which are summarized below and reprinted in 

appendix III.

We are sending copies of this report to the Department of Homeland 

Security, the Administrator of the General Services Administration, 

selected congressional committees, and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov.

Should you or your staff have any questions concerning this report, 

please contact Joseph Kirschbaum at (202) 512-9971 or by e-mail at 

 

34Agency comments were made on GAO-13-706. This report number was 

subsequently changed to GAO-14-101.

Agency Comments
 

Page 21 GAO-14-101 Federal Facility Evacuations

kirschbaumj@gao.gov or Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

Key contributors to this report are listed in appendix IV.

Sincerely yours,

Joseph Kirschbaum 

Acting Director, Homeland Security and Justice

Mark Goldstein 

Director, Physical Infrastructure
Appendix I: Objectives, Scope, and 

Methodology

Page 22 GAO-14-101 Federal Facility Evacuations

This report describes

1. who is responsible for ensuring that federal facilities have occupant 

emergency plans (OEP) in place and the extent to which selected 

facilities’ OEPs reflect federal guidance and

2. evacuation challenges, if any, that selected facilities experienced and 

what actions, if any, they reported taking to address these issues.

To describe who is responsible for ensuring that federal facilities have 

OEPs in place, we reviewed federal laws, regulations, executive orders, 

and guidance related to the oversight of federal facilities. This included 

relevant sections of the Homeland Security Act of 2002; the regulations 

regarding federal property facility management and federal agency 

requirements for OEPs; Executive Order 12977, establishing the 

Interagency Security Committee (ISC); and Executive Order 13286, 

amending it.1 We reviewed OEP guidance issued by ISC, the Federal 

Protective Service (FPS), and the General Services Administration 

(GSA).2 We also reviewed our previous work on the roles of FPS, GSA, 

and ISC in protecting federal facilities.3

 

1

Pub. L. No. 107-296, 116 Stat. 2135; 41 C.F.R. pt. 102-74; Exec. Order No. 12,977, 60 

Fed. Reg. 54,411 (Oct. 19, 1995); Exec. Order No. 13,286, 68 Fed. Reg. 10,619 (Feb. 28, 

2003).

We interviewed relevant senior 

agency officials regarding their agencies’ role in ensuring federal facilities 

have OEPs in place, including ISC officials in Washington, D.C.; officials 

from FPS and GSA in their headquarters; and FPS and GSA officials in 

the three field locations where we conducted site visits to selected federal 

facilities, as described below.

2

Among others, guidance we reviewed included: ISC, Physical Security Criteria for 

Federal Facilities: An Interagency Security Committee Standard (Washington, D.C.: Apr. 

12, 2010), and Occupant Emergency Programs: An Interagency Security Committee 

Guide (Washington, D.C.: March 2013); FPS, Secure Facilities, Safe Occupants–

Occupant Emergency Plans: Development, Implementation and Maintenance, Updated 

May 2010, and related supplements (Washington, D.C.); and GSA Public Buildings 

Service, Occupant Emergency Program Guide (Washington D.C.: 2002). 

3

GAO, Federal Real Property Security: Interagency Security Committee Should 

Implement a Lessons-Learned Process, GAO-12-901 (Washington, D.C.: Sept. 10, 2012); 

Federal Protective Service: Actions Needed to Resolve Delays and Inadequate Oversight 

Issues with FPS’s Risk Assessment and Management Program, GAO-11-705R 

(Washington, D.C.: July 15, 2011); and Homeland Security: Greater Attention to Key 

Practices Would Improve the Federal Protective Service’s Approach to Facility Protection, 

GAO-10-142 (Washington, D.C.: Oct. 23, 2009). 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 23 GAO-14-101 Federal Facility Evacuations

To describe the extent to which the selected facilities’ OEPs reflect 

federal guidance, we conducted site visits at 20 of the GSA facilities 

protected by FPS.4

• We selected three geographically diverse areas with a concentration 

of GSA facilities from GSA’s top 15 major real estate markets. 

Specifically, we selected two areas from the top 5 markets in terms of 

GSA assets (Los Angeles, California, and Washington, D.C.), and one 

area from a smaller GSA market defined as having fewer than 100 

facilities (Kansas City, Missouri).

We selected a nonprobability sample of facilities as 

follows:

• To ensure a subset of facilities would be able to discuss evacuation 

experiences they have had, we selected 9 facilities total from the 

three areas that had reported an evacuation incident to an FPS 

MegaCenter during 2011 or 2012. Each of the four FPS MegaCenters 

records incidents such as fire alarms, suspicious packages, and 

evacuation drills that are reported to that center as part of the center’s 

operations log, with an activity code that can be queried for incidents. 

Only incidents reported to a MegaCenter are captured, so, for 

example, if local police respond to a call at a facility and do not call 

FPS, the incident would not be included in the MegaCenter data. 

According to discussions with MegaCenter data officials and a review 

of the data content, we determined that the incident data were reliable 

for our purposes, as our sample was not intended to be representative 

of all incidents.5

• We used a list provided by GSA from its Real Estate Across the 

United States (REXUS) database to select the remaining 11 facilities 

to provide a mix of owned and leased properties, and a mix of facility 

security levels. We determined that the REXUS database was reliable 

for our purposes based on a review of database documents and 

 

4

GSA reported having over 9,600 assets, or 11 percent of all federal square footage, as of 

September 2011, which includes office buildings, courthouses, warehouses, laboratories, 

parking lots, and other properties. We limited our facility selection to the almost 7,900 

GSA office buildings, of which 7,301 are office spaces that GSA leases. For the purposes 

of this report, we used the term “facilities” to describe the 20 GSA assets in our sample.

5

In addition to the 9 facilities we selected using the incident data, officials at an additional 

7 facilities reported during our interviews that they had evacuated in the last 3 years, for a 

total of 16 facilities with evacuation experience.
Appendix I: Objectives, Scope, and 

Methodology

Page 24 GAO-14-101 Federal Facility Evacuations

discussion with relevant GSA officials. See table 2 for a summary of 

characteristics of the 20 facilities we selected.

Table 2: Selected Facility Characteristics of the 20 Case Study Facilities in Our 

Review

Washington, 

D,C.

Kansas City, 

Missouri

Los Angeles, 

California Total

Total facilities 6 7 7 20

Facility security level (FSL)a

FSL-IV 3 3 3 9 

FSL-III 2 1 2 5 

FSL-II 1 3 2 6 

Facilities reporting 

they evacuated in 

the last 3 years

6 5 5 16

General Service 

Administration 

(GSA)–owned 

facilities

4 2 3 9 

GSA-leased facilities 2 5 4 11

Source: GAO analysis of selected facility characteristics.

a

A FSL of I to V is assigned by FPS to facilities it protects. A higher-numbered FSL facility would be 

considered a facility with a higher security risk than a facility with a lower number.

For all selected facilities, we reviewed the extent to which the OEPs 

included the 10 minimum elements that should be included based on 

ISC’s Physical Security Standard (ISC 2010 standard) for federal 

facilities.6

 

6

ISC, April 12, 2010. We used the ISC 2010 list of OEP elements because ISC’s March 

2013 guidance was not finalized when we conducted our work, or when the plans we 

reviewed were developed. Officials said the 2010 elements are incorporated in the 2013 

guidance.

For example, 1 element that an OEP should include is 

information on “Special Needs Individuals (disabled, deaf, etc.).” For each 

facility in our sample, two team members reviewed the OEP and 

assessed whether or not each of the elements was addressed. The ISC 

2010 standard indicates that the 10 elements should be present; 

however, it notes that the scope and complexity of the OEP are 

dependent on the facility’s size, population, and mission, and the 

standard does not provide a description of, or detail on, what should be 

included for each element. Further, not all elements may be applicable for 
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-14-101 Federal Facility Evacuations

a facility, for example, if the facility does not have a child care or other 

special facility.7 Because of the general nature of the elements, we 

assessed whether a particular element was present in a facility’s OEP, 

not its quality or comprehensiveness. We reviewed additional documents 

provided by agency officials, such as child care center emergency plans, 

emergency cards for quick use, and FPS’s facility security assessment 

protocol, used by FPS inspectors when periodically checking OEPs.8

To describe the challenges and evacuation experiences of the 20 

selected facilities, we discussed specific evacuation instances with facility 

and GSA officials, the challenges officials face in planning and executing 

evacuation plans, and any steps taken to mitigate the challenges. We 

asked about evacuation challenges in general, and about specific 

challenges that were identified by a review of the literature and from 

discussion with FPS. We also asked officials at the facilities we visited 

about challenges, and they determined whether they perceived an issue 

to be a challenge or not. Where available, we reviewed after-action 

reports documenting facility evacuation experiences. We also discussed 

evacuation experiences and challenges with ISC, GSA, and FPS officials. 

Our findings regarding what issues presented challenges and how such 

challenges could be resolved cannot be generalized to all GSA-owned 

and -leased facilities; however, they provide specific examples of issues 

encountered and how varying facilities addressed them.

We 

also interviewed GSA property managers and officials from agencies who 

occupy each facility about the facility’s plan. Further, those officials were 

those identified by GSA and the tenant agency as most knowledgeable 

about the OEP, which in some cases was the designated official, and in 

other cases, the facility official was, for example, a manager involved with 

facility security. While the findings from our 20 case studies are not 

generalizable to all GSA-owned and -leased facilities, they provide 

specific examples of how selected facilities have addressed emergency 

plan requirements and provide insights from a range of federal facilities.

 

7

In instances where a particular element was not applicable, but the OEP had all other 

elements, we considered the OEP as addressing all applicable elements. 

8

Department of Homeland Security, Federal Protective Service Modified Infrastructure 

Survey Tool; Security Management Profile, (Washington, D.C.: March, 2012) (Official use 

only.) 
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-14-101 Federal Facility Evacuations

We conducted this performance audit from August 2012 to October 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Examples of How OEP Elements 

Were Included in 20 Selected Facilities’ 

Emergency Plans

Page 27 GAO-14-101 Federal Facility Evacuations

Facility plans we reviewed addressed the ISC minimum 10 elements in a 

variety of ways, consistent with agency guidance and facility 

characteristics. Guidance in the ISC 2010 Physical Security Criteria for 

Federal Facilities notes that an OEP’s scope and complexity will be 

dependent on a facility’s size, population, and mission.1

Table 3: How Selected Facility Occupant Emergency Plans (OEP) Addressed Interagency Security Committee OEP Elements 

Table 3 presents 

excerpts from OEPs from the 20 selected facilities we visited in 

Washington, D.C.; Kansas City, Missouri; and Los Angeles, California; 

and were selected to show the variation in how plan elements were 

addressed.

Purpose and circumstance

• Purpose: “This OEP and support documents are intended to foster pre-planning knowledge, training and rehearsal, so 

consequences of emergency events may be mitigated.” Activation: “The Occupant Emergency Plan may be activated when an 

emergency situation occurs. Typical emergency events, which could cause activation, are fire, chemical spill, tornado, 

earthquake, and radiological contamination, among others.” (FSL-III)a

• Purpose: “This plan directs the implementation of an incident command system, notification of (agency) and local emergency 

officials, building evacuation, shelter in place actions, active shooter procedures, and a personnel accountability system in the 

event of a suspected or actual emergency at (facility).” Activation: “Any incident that may present an immediate danger to the life 

and health of an individual, or multiple occupants.... These incidents include visible fire or smoke conditions, emergent sick or 

injured employees, explosions, gun fire, “active shooter incidents,” assaults (in progress), and hostage situations. (FSL-IV) 

Command officials and supporting personnel contact information

• The OEP identifies the titles, names, and numbers for the OEP organization including the designated official, occupant 

emergency coordinator, floor team coordinator, and so forth and alternates for each position. (FSL-IV)

• “The Occupant Emergency Team structure is consistent with the incident command system and National Incident Management 

System.” The OEP provides team member positions, office and cell phone contacts, and team member responsibilities. (FSL-III) 

Occupant life-safety options (evacuation, shelter in place)

• The OEP covers partial evacuations, full evacuations, shelter in place, areas of assembly, specific emergency situations, and the 

roles of emergency evacuation team members. (FSL-II)

• The OEP specifies the methods by which total or selective evacuation will take place, which can be the result of many situations 

(fire, bomb threat, or other emergencies) that mandate clearing the facility, and describes situations that would require employees 

to shelter in place. (FSL-IV) 

Local law enforcement and first responder response (coordination and contact information) 

• The OEP states that communications with government agencies, community organizations, and utilities are important in 

orchestrating an effective emergency response strategy, and lists those entities with contact information. (e.g., Washington, D.C., 

Police Department, local hospitals). (FSL-IV)

• The OEP includes contact information for local police; fire, and the Federal Protective Service officials said that FPS will notify 

local law enforcement in an emergency, and that FPS has memorandums of agreement in place with local police, sheriffs, and 

the highway patrol. (FSL-IV) 

 

1

An Interagency Security Committee Standard, April 12, 2010.

Appendix II: Examples of How OEP 

Elements Were Included in 20 Selected 

Facilities’ Emergency Plans
Appendix II: Examples of How OEP Elements 

Were Included in 20 Selected Facilities’ 

Emergency Plans

Page 28 GAO-14-101 Federal Facility Evacuations

Purpose and circumstance

Evacuating special needs individuals (disabled, deaf, etc.) 

• The facility utilizes guidelines of the U.S. Equal Employment Opportunity Commission (EEOC) on emergency evacuation 

procedures for special needs employees. However, all employees with special needs must take personal responsibility to notify

and consult with their supervisors of their special needs before an emergency occurs. (FSL-IV)

• The OEP designates an employee with disabilities monitor who is responsible for establishing a predesignated location, such as 

the nearest stairwell, to meet the assigned monitor during an alarm. The OEP provide guidelines for the monitor, who is 

responsible for remaining with the employee at the predesignated area. The monitor is also responsible for using the evacuation 

chair to evacuate the employee if possible. (FSL-II) 

Visitors (public and contractors)

• Officials at 1 facility we visited said that the facility hosts over 1,000 visitors per day. The OEP “applies to all employees, 

contractors and visitors” and “If an employee or contractor has a visitor, or is the host of a meeting or briefing with visitors, then 

they are responsible for the safety and security of their visitors.” (FSL-IV)

• The OEP states that it applies to all employees, support contractors, and visitors occupying the facility, and that employees are 

responsible for escorting their guests, visitors, and vendors out of the building. If there is a shelter-in-place emergency situation, 

the OEP says that if there are customers, clients, or visitors in the building, provide for their safety by asking them to stay—not 

leave. (FSL-II) 

Special facilities (e.g., sensitive information facilities, child care centers)

• “Each staff member shall be assigned a specific group of children for whom he or she is to be responsible during an emergency.

Center staff should conduct practice drills over the prescribed evacuation routes so children will not be unprepared or unduly 

alarmed should a real emergency occur.” The OEP assigns a specific guard post to escort staff and children in an emergency. 

(FSL-IV)

• The OEP addresses Classified National Security Information and Sensitive Compartmented Information Facilities. “Upon 

receiving a report of fire or emergency activation, employees working with classified material shall, if safe to do so, secure 

classified material properly before exiting. This would include securing electronic media, paperwork, etc. in a GSA-Approved 

storage container. Close and properly lock all containers. Close doors and engage the intrusion detection system on your way 

out.” (FSL-IV)

Assembly and accountability (staging and tracking of employees in identified area)

• The OEP provides for primary and alternate assembly areas, and identifies the designated official as responsible for accounting 

for all employees. After accounting for all employees, the designated official will contact the appropriate emergency personnel 

identified in the plan. Upon arrival of law enforcement personnel, responsibility for assembly and accountability is turned over to 

law enforcement officials. All employees are directed to wait for instructions and the all-clear signal. (FSL-II)

• Office managers should select an official rendezvous area from one of the designated assembly areas. They must then advise 

their employees which designated assembly area they have selected. Officials at this facility told us that the facility had multiple 

evacuation assembly points and changed the locations as a deterrent to possible secondary harmful actions (such as a bomb at 

the assembly area). Office managers are responsible for accounting for all of their employees once they have assembled at the 

rendezvous point at the designated assembly area. (FSL-IV)

Security during and after incident (protection of employees)

• The OEP delegates security during and after incidents to the facility contract security guards, and states that it is critical that 

security guards or law enforcement take charge of any incident that may involve physical harm. (FSL-IV)

• FPS provides advice and assistance, as necessary to the command team, assists in controlling building population during 

evacuation and subsequent reentry to the building, and provides traffic control. The facility guard post is responsible for 

controlling entrances and exits, as necessary. (FSL-III)
Appendix II: Examples of How OEP Elements 

Were Included in 20 Selected Facilities’ 

Emergency Plans

Page 29 GAO-14-101 Federal Facility Evacuations

Purpose and circumstance

Plan specifies that emergency training or exercises be conducted

• The OEP provides that supervisors are responsible for ensuring that their staff are aware of emergency procedures and receive

the necessary training. Officials at this facility told us that four drills—an evacuation, shelter in place, lockdown of the facility, and 

evacuation for disabled occupants—are conducted annually. (FSL-IV)

• The OEP indicates that managers are responsible, on a recurring basis, to discuss OEP procedures with employees, including 

evacuation routes, assembly points, shelter-in-place locations, assignments as special/personal assistance aids/monitors, and 

floor wardens/monitors they assist. (FSL-II) 

Source: GAO analysis of selected sections of facility OEPs.

a

FPS assigns an FSL of I to V to facilities it protects. A higher-numbered FSL facility would be 

considered a higher security risk than a lower-numbered FSL facility.
Appendix III: Comments from the Department 

of Homeland Security

Page 30 GAO-14-101 Federal Facility Evacuations

Appendix III: Comments from the 

Department of Homeland Security

Agency comments were 

made on GAO-13-706. 

This report number was 

subsequently changed to 

GAO-14-101.
Appendix III: Comments from the Department 

of Homeland Security

Page 31 GAO-14-101 Federal Facility Evacuations
Appendix IV: GAO Contacts and Staff 

Acknowledgments

Page 32 GAO-14-101 Federal Facility Evacuations

Joseph Kirschbaum, 202-512-9971, or kirschbaumj@gao.gov, 

Mark Goldstein, 202-512-2834, or goldsteinm@gao.gov. 

In addition to the contacts named above, Leyla Kazaz (Assistant 

Director), Tammy Conquest (Assistant Director), Dorian Dunbar, Eric 

Hauswirth, Mary Catherine Hult, Monica Kelly, Tracey King, Erica Miles, 

Linda Miller, and Kelly Rubin made key contributions to this report.

Appendix IV: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Staff 

Acknowledgments 

(441096)
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